Your California Privacy Rights

Shine the Light

If you are a resident of the State of California and would like to learn how your "personal information" (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please email us at: [email protected]

Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third party for marketing purposes, please email us at: [email protected]

Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.

California Consumer Privacy Act (CCPA)

In addition to the foregoing, if you are a resident of the State of California, certain other privacy-related rights may apply to you in accordance with the CCPA, including the right to opt-out of our sale of your Personal Information, as well as the right to know what Personal Information about you we have collected, whether your Personal Information was shared with third-parties in the preceding year and, if so, what categories of Personal Information were shared, as well as the categories of third parties with whom we shared that Personal Information.

Privacy Provisions for California Residents

These Privacy Provisions for California Residents ("Provisions") supplement, and do not limit in any way, the Privacy Policy set forth on this site. These Provisions apply solely to residents of the State of California ("CA Users"). We adopt these Provisions in compliance with the California Consumer Privacy Act of 2018 ("CCPA"). Any terms defined in the CCPA have the same meaning when used in these Provisions. Users with disabilities who wish to access these Provisions in an alternative format can contact us by emailing: [email protected]

Categories of Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or device ("personal information"). In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, telephone number, or other similar identifiers.	YES
B. California Customer Records	Name, signature, SSN, physical characteristics, postal address, telephone number, passport number, driver's license, insurance policy number, education, employment, bank account number, credit card number, medical information, or health insurance information.	YES
C. Protected Classification Characteristics	Age (40+), race, color, ancestry, national origin, citizenship, religion, marital status, medical condition, disability, sex, sexual orientation, veteran status, genetic information.	NO
D. Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric Information	Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or identifier, such as fingerprints, faceprints, voiceprints, iris or retina scans.	NO
F. Internet or Network Activity	Browsing history, search history, information on a CA User's interaction with a website, application, or advertisement.	YES
G. Geolocation Data	Physical location or movements.	NO
H. Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional/Employment Information	Current or past job history or performance evaluations.	NO
J. Non-Public Education Information	Education records directly related to a student maintained by an educational institution, such as grades, transcripts, class lists, student schedules.	NO
K. Inferences	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Personal information does not include:

• Publicly available information from government records
• De-identified or aggregated CA User information
• Information excluded from the CCPA's scope, such as health or medical information covered by HIPAA, or personal information covered by sector-specific privacy laws including FCRA, GLBA, or the Driver's Privacy Protection Act of 1994

We obtain the categories of personal information listed above from the following sources:

• Directly from CA Users — from online registration and case review forms submitted through the Site. (Category A, B and D)
• Indirectly from CA Users — through information collected in the course of providing our services. (Category A, B, D and F)
• Automatically from Site activity — browser type, IP address, operating system, domain name of your ISP, and site usage analytics. (Category F)
• From third parties — entities that assist us in sending mail, analyzing data, and providing marketing analysis. (Category A, B, D and F)

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided, such as processing your case review request (Category A, B and D)
• To provide you with information, products, or services that you request from us (Category A, B, D and F)
• To create, maintain, customize, and secure your account with us (Category A, B, D and F)
• To provide you with email, direct mail, and telemarketing messages concerning our services and third-party services we believe may interest you (Category A, B, D and F)
• To deliver relevant Site content and advertisements and measure advertising effectiveness (Category A, B, D and F)
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us (Category A, B, D and F)
• To improve the Site and better present its contents to you (Category A, B, D and F)
• For customer service purposes and to respond to your inquiries (Category A, B and D)
• For testing, research, analysis, and product development (Category A, B, D and F)
• To protect our rights, property, or safety, and that of our clients or others (Category A, B, D and F)
• To respond to law enforcement requests and as required by applicable law or court order (Category A, B, D and F)
• To evaluate or conduct a merger, divestiture, restructuring, or other sale or transfer of our assets (Category A, B, D and F)

Sharing Personal Information

Subject to your right to opt-out, we may share, rent, and/or sell your personal information from Categories A, B, D and F with third parties for marketing purposes and for the other business purposes set forth above. When we disclose personal information to a third-party service provider, we enter into a contractual relationship describing the purpose for which such third party may use the personal information.

We do not collect information from CA Users we actually know are less than 18 years of age, and we do not share or sell the personal information of CA Users we actually know are less than 16 years of age.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• Category A — Identifiers
• Category B — California Customer Records personal information categories
• Category D — Commercial information
• Category F — Internet or other similar network activity

Your Rights and Choices

Opt-Out from the Sale of Your Personal Information

You have the right to opt-out of our sale of your personal information to third parties. To exercise this right, please submit a verifiable CA User request by emailing: [email protected]. We endeavor to act on all opt-out requests within fifteen (15) days of receipt.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose:

• The categories of personal information we collected about you
• The categories of sources for the personal information we collected about you
• Our business or commercial purpose for collecting or selling that personal information
• The categories of third parties with whom we have shared that personal information
• The specific pieces of personal information we collected about you (data portability request)
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing sales and disclosures by recipient category

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary to:

• Complete a transaction or provide a service you requested
• Detect security incidents or protect against fraudulent or illegal activity
• Debug products to identify and repair errors
• Comply with a legal obligation
• Make other internal and lawful uses of that information compatible with the context in which you provided it

Exercising Your Rights

To exercise your access, data portability, and/or deletion rights, please submit a verifiable CA User request by emailing: [email protected]

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information. You may only make a verifiable CA User request for access or data portability twice within a 12-month period.

Response Timing and Format

We endeavor to respond to all verifiable CA User requests within forty-five (45) days of receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable CA User request unless it is excessive, repetitive, or manifestly unfounded.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services, charge you different prices, provide a different level or quality of goods or services, or suggest that you may receive different pricing or service levels.

Changes to These Privacy Provisions

We reserve the right to amend these Privacy Provisions at any time. When we make changes, we will notify you by email or through a notice on the Site's homepage.

Contact Information